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Investment Advisers

SEC3 offers an extensive suite of customizable compliance services for investment advisers, on either a one-time or recurring basis depending on your needs.

Examples of potential services include, but are not limited to:

  • Annual Compliance Reviews
  • Quarterly Compliance Reviews
  • Due Diligence Reviews
  • Risk Assessment and Gap Analysis
  • Compliance Testing and Analysis
  • Mock SEC Examinations
  • Compliance Training
  • Customized Compliance Services

Annual Compliance Review

For registered advisers, the Compliance Rule requires each adviser to review its policies and procedures, at least annually, to determine their adequacy and the effectiveness of their implementation. In Annual Compliance Review services, SEC3 can assist Chief Compliance Officers in every phase of the annual review process, from formulating a strategic plan, to conducting thorough assessments and testing of all aspects of the compliance program, to planning for next year's review. SEC3's Annual Compliance Review allows advisers to maximize available resources by fulfilling specific elements or the entire scope of the regulatory obligation. The Annual Compliance Review can conclude with a customizable, easy to read report and action plan.

Quarterly Compliance Reviews

Most advisers would prefer to diversify the strain on operational and financial resources of an annual review over the course of the year, which is why SEC3 offers its flagship service, the Quarterly Compliance Review, as the perfect solution. Quarterly Compliance Reviews conduct all the aspects of the annual review over the course of the year in manageable phases while revisiting critical and changing areas throughout the year. The dynamic scope and disciplined approach of Quarterly Compliance Reviews stimulates the evolution of the compliance program, keeping it continually current and addressing any issues as they appear. Quarterly Compliance Reviews optimize compliance resources and limit the interruption of your firm. Like the Annual Compliance Review, each Quarterly Compliance Review can conclude with a customizable, easy to read report and action plan.

Additionally, Quarterly Compliance Reviews address the essential, on-going demands of a compliance program, such as managing disclosure documents, filing requirements, and compliance policies and procedures. Quarterly Compliance Reviews provide the opportunity for SEC3's professionals to establish a deep partnership with each adviser and fund and actively participate in the compliance program.

Risk Assessment & Gap Analysis

The Risk Assessment & Gap Analysis not only fulfills regulatory expectations, it provides valuable insights into your risk profile and your exposure to those risks. SEC3's Risk Assessment & Gap Analysis is a system that considers the likelihood and impact of the compliance risk specific to each advisory firm or fund and assesses how well the existing controls mitigate those risks. The Risk Assessment & Gap Analysis report is a concise, but detailed summary in plain English that prioritizes risks by exposure, arming the Chief Compliance Officer and Independent Directors with the critical information to immediately implement an action plan.

Compliance Testing & Analysis

Forensic tests are the eyes and ears of the Chief Compliance Officer. Without rigorous, consistent forensic testing, a Chief Compliance Officer has no early warning systems. Various forensic tests are means to identify symptoms of potential compliance problems and can serve as confirmation that the compliance program is functioning properly. SEC3 can assist Chief Compliance Officers in designing and conducting a battery of rigorous and periodic forensic compliance tests as part of the continuous monitoring of the compliance program; including, but not limited to, trading and execution, portfolio compliance, code of ethics, account administration, and investment performance.

Mock SEC Examinations

Much of the fear surrounding a regulatory examination stems from the "unknown" element. A Mock SEC Examination is an effective process to gauge the types of exposures and concerns that an adviser or fund would face during a real regulatory examination. Mock SEC Examinations use current exam focuses, with proven exam approaches and methodologies, including interviews, reviews of policy and procedures, analysis, and testing, and conclude with a customizable summary of assessments, recommendations, and proposed solutions. SEC3's professionals, with years of experience as senior examiners with the Securities and Exchange Commission or as compliance professionals, provide expert insight and guidance. Mock SEC Examinations pierce the mystique of a regulatory examination and transform an often stressful experience into a valuable assessment process that allows a Chief Compliance Officer and the compliance staff to face a future regulatory examination with confidence and peace of mind.

Compliance Training

Drafting and adopting reasonable policies and procedures is only part of the successful implementation of a compliance program; effective compliance training is also essential. The success of a compliance program is predominately determined by the ability of the adviser's or fund's staff to consistently fulfill the goals and functions of the policies and procedures. SEC3's professionals will assist Chief Compliance Officers in developing and conducting customized training programs to your staff on the various aspects of your compliance program and their responsibilities under that program. Our belief is that training should rejuvenate the staff's awareness and sensitivity of compliance policies while reinforcing the importance of each person's role in the compliance program.

Other customized services include:

  • Development and Implementation of Customized Compliance Policies and Procedures
  • Compliance Calendar & Planning Assistance
  • SEC Examination and Inquiry Response
  • Deficiency Letter Response and Remedial Action Plans
  • Form ADV and IARD Filings and Reviews
  • Registration Assistance: State and Federal
  • Disclosure Reviews

Newsletter

Get the latest compliance news and insights - delivered weekly. The SEC3 Communique covers all compliance topics. CCO3 focuses on Mutual Fund CCO topics.
tip: check both to keep informed!

Communiques

New SEC Guidance for Investment Advisers’ Obligations Regarding Proxy Voting

The SEC’s Divisions of Investment Management and Corporation Finance recently provided guidance (the “Guidance”) to investment advisers regarding their obligations in voting client proxies and retaining proxy advisory firms. ... read more »

Steps Directors Can take to Avoid SEC Enforcement

SEC Chair Mary Jo White recently shared steps directors can take to meet various SEC expectations. At the annual Stanford Directors’ College, Chair White highlighted the important role directors play... read more »

Understanding SEC Enforcement

One of the main goals of any registered firm is to avoid an enforcement action.  The more you know about trends with regard to enforcement cases, the better equipped you... read more »

SEC Risk Alert - Cyber Security

As if April 15th wasn't bad enough? In addition to it being Tax Day, the U. S. Securities Exchange Commission's ("SEC") Office of Compliance Inspections and Examinations ("OCIE") issued a... read more »

If You Have Never Been Examined by the SEC, Get Ready

The Securities and Exchange Commission announced on Thursday, February 20th that its Office of Compliance Inspections and Examinations (OCIE) is launching an initiative directed at investment advisers that have never... read more »

SEC National Exam Program 2014 Exam Priorities

The Securities and Exchange Commission’s National Examination Program (“NEP”) has released 2014 examination priorities which can be found here. Much of what has been announced is a reiteration of... read more »

Events

GAIM Ops Ireland 2014

When: October 8-10th, 2014 Where: Powerscourt Hotel, Wicklow Ireland

IA Compliance Fall Conference 2014

When: September 22th, 2014 Where: Loews Philadelphia Hotel

NYC CCO Compliance Roundtable

When: September 23rd 2014 Where: Blank Rome LLP, The Chrysler Building, 405 Lexington Avenue, 22nd Floor Board Room